Search - 德国民法典第1993条

1993 External T.I. 9321175 F- Transfer of Farm Property-- summary under Subsection 73(3) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(3) It is not necessary that a particular asset be used in farming at a point in time immediately prior to the transfer. ...

9 February 1993 T.I. (Tax Window, No. 29, p. 3 ¶2436)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Mortgages taken back by a developer in order to facilitate sales may initially be assets used in an active business, but will become investments if retained for more than a short period. ...

30 November 1992 T.I. 923168 (September 1993 Access Letter, p.423, ¶C144-238)-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) Bonus interest payments paid by a credit union directly to the annuitant of an RRSP would be included in the annuitant's income under s. 146(8). ...

5 May 1993 T.I. (Tax Window, No. 31, p. 13, ¶2526)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where the costs of providing health care are taken into account by the employer in determining an employee's compensation, the amounts paid into the private health services plan will be considered to have been paid by the employee, with the result that the supposed payments to the private health services plan by the employer will be included in the employee's income under s. 5 or s. 6(1)(a). ...

17 May 1993 T.I. (Tax Window, No. 31, p. 12, ¶2525)-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) Where a taxpayer sells shares of a U.S. corporation and receives in exchange therefor an interest-bearing note under which no payments of accrued interests are required for the first three years, with the result that the note is subject to the interest accrual rules under s. 12(4), the taxpayer is not entitled to a foreign tax credit under s. 126(1) until the tax actually is paid. ...

18 May 1993 T.I. (Tax Window, No. 31, p. 4, ¶2511)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Where a widely-held public corporation (A) issues treasury shares pursuant to a takeover bid to the shareholders of B (another widely-held public corporation) in exchange for their shares of B, and the exchange ratio is such that the former shareholders of B thereby acquire a majority of the issued shares of A, there will be an acquisition of control of B by A. ...

3 February 1993 T.I. (Tax Window, No. 28, p. 14, ¶2415)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation In order for land to be considered to be used in an active business, it generally must be subjacent to any building or structure affixed to the land or immediately contiguous land used as a parking area, driveway, yard, garden or similar land that is necessary for the use of the building. ...

23 June 1993 T.I. (Tax Window, No. 32, p. 13, ¶2608)-- summary under Exempt Surplus Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Exempt Surplus Where a foreign corporation with a December year-end pays a dividend in June and then becomes a foreign affiliate of a Canadian corporation in October, the dividend so paid will not be deducted from exempt or taxable surplus of the foreign corporation in relation to the Canadian corporation because it will not be a "whole dividend" as defined in Regulation 5907(1)(n), i.e., the dividend was paid prior to the Canadian corporation acquiring shares of the foreign affiliate. ...

16 March 1993 T.I. (Tax Window, No. 30, p. 15, ¶2478)-- summary under Subparagraph 212(1)(d)(iii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(iii) Payment for services of a non-resident engineer at an hourly rate of $125 would not appear to dependent upon the "use to be made of" or the "benefit to be derived from" such services. ...

26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt For farmers on the cash method, a post-dated cheque that is received on a date that a debt owing to the taxpayer is not yet payable will be brought into income on the earlier of the date the debt becomes payable and the date the cheque is negotiated. ...